Heat network zoning in Scotland and Wales compared with England
Last verified 4 min read
Each nation of Great Britain has taken its own approach to heat network zoning. The result is three different systems, at three different stages. Northern Ireland is outside the scope of this site.
This site tracks England. This explainer sets out how England, Scotland and Wales compare, so that readers in each can see where their rules come from.
The short version
| England | Scotland | Wales | |
|---|---|---|---|
| Zoning law | Energy Act 2023, regulations pending | Heat Networks (Scotland) Act 2021 | None |
| Zones designated | None yet | None found | Not applicable |
| Local heat planning | Zoning pilot and zone opportunity reports | Statutory local heat strategies | Local area energy plans |
| Market regulator | Ofgem | Ofgem | Ofgem |
The rest of this page explains each row.
England
Zoning in England comes from the Energy Act 2023, Part 8, Chapter 2 (sections 226 to 237)[source]. Where it applies: England only[source].
The Act gives the government the power to create zones, but nothing happens until regulations are made under it. Their status: Not yet laid before Parliament[source]. Once they are in force, a central zoning authority will oversee the system, councils or combined authorities will coordinate individual zones, and developers chosen by competition will build the networks. Our explainer on who runs zoning sets this out.
England's approach is top-down in one important respect. The government sets a national method for identifying zones and has worked with 28 pilot places to test it. The places tracker shows where each has got to.
Scotland
Scotland legislated first. Its framework: Separate regime under the Heat Networks (Scotland) Act 2021[source]. That law sits outside the Energy Act 2023 entirely.
The Scottish law includes its own zoning powers: Councils or Scottish Ministers can designate heat network zones under Part 3 of the 2021 Act, in force since 30 May 2023[source]. The approach gives councils a larger role than England's. Under Part 3 of the Act, each local authority must review its area for places suitable for heat network zones.
Scotland also has a statutory duty on councils to plan local heat. Every Scottish council had to publish a strategy and delivery plan by 31 December 2023, updated at least every 5 years[source]. These Local Heat and Energy Efficiency Strategies, known as LHEES, map where heat networks and other low-carbon heating are likely to suit each area. They are the main evidence base for identifying zones. The Scottish Government's guidance sets out what each strategy must contain.
The Scottish Act also sets binding national targets: 2.6 TWh of heat from networks by 2027, 6 TWh by 2030 and 7 TWh by 2035[source]. Progress has been slower than planned. The Scottish Government's 2026 review of its heat networks delivery plan estimates that networks supplied about 1.57 TWh in 2025, well short of the 2027 target.
At our last check we had found no heat network zone formally designated in Scotland. The same 2026 review describes councils working towards their first zones.
Wales
Wales has taken a slower, more exploratory route. Its position: No zoning regime; the Welsh Government is assessing whether the Energy Act 2023 zoning powers are needed[source].
The Welsh Government's Heat Strategy action plan, published in July 2024, commits to using local area energy plans to identify where zoning might be useful. It then commits to assessing whether zoning powers are needed in Wales at all. Until that decision is made, there is no route to designate a zone in Wales.
Welsh projects are not cut off from funding. The Green Heat Network Fund has opened to Welsh projects, and the efficiency scheme for existing networks already covered Wales: £107m of grants from 2023-24 to 2029-30 to improve existing heat networks in England and Wales[source].
What all three share: market regulation
Zoning decides where networks go. A separate set of rules governs how networks treat their customers, and these apply across Great Britain.
Ofgem became the regulator for heat networks in England, Scotland and Wales on 27 January 2026[source]. Network operators in all three nations must now be authorised and meet the same conditions on pricing, billing and customer care.
Consumer advocacy is split by nation. In England and Wales the statutory advocate is Citizens Advice, for heat network consumers in England and Wales[source]. In Scotland it is Consumer Scotland, from 1 April 2025[source]. Complaints in all three can go to the Energy Ombudsman. Our Ofgem page has the detail.
Why the approaches differ
The differences partly reflect timing. Scotland set targets and zoning powers before England had settled its own design. England chose to test its method through a national pilot before writing regulations. Wales is still weighing whether zoning is the right tool for its mix of towns and rural areas.
They reflect different kinds of evidence, too. England's pilot produced a zone opportunity report for each of its 28 places, written by engineering consultancies under a common government method and published in 2025. Scotland relies on each council's own heat strategy, which also covers energy efficiency and other ways of heating homes. Wales is starting from local area energy plans, which look at the whole local energy system rather than heat alone.
They also reflect where power sits. In Scotland, councils lead on identifying zones. In England, the government sets the method and a central authority will oversee designation, with councils coordinating locally. Each nation is trying to solve the same problem described in our explainer on why the UK is zoning heat networks: making sure networks reach enough buildings to be worth building.
Where this site fits
This tracker covers England only, because that is where the Energy Act 2023 zoning regime applies. England's own ambition is: 7% of England's heat (27 TWh) by 2035[source]. For Scotland, the Scottish Government's heat networks pages are the primary source. For Wales, the Welsh Government's heat strategy is the place to start.
Facts used in this explainer
| Item | Position | Status |
|---|---|---|
| Where zoning applies | England onlyEnergy Act 2023, Part 8, Chapter 2: heat network zones (legislation.gov.uk) | In force |
| Legal powers for heat network zones | Energy Act 2023, Part 8, Chapter 2 (sections 226 to 237)26 October 2023 · Energy Act 2023, Part 8, Chapter 2: heat network zones (legislation.gov.uk) | In force |
| Heat network zoning regulations | Not yet laid before ParliamentExpected 2026–27 · The role of heat networks in the energy transition (GOV.UK speech by the energy minister, 22 Oct 2026) | Pending |
| Scotland | Separate regime under the Heat Networks (Scotland) Act 2021Heat Networks (Scotland) Act 2021 (legislation.gov.uk) | In force |
| Zoning in Scotland | Councils or Scottish Ministers can designate heat network zones under Part 3 of the 2021 Act, in force since 30 May 202330 May 2023 · Heat Networks (Scotland) Act 2021, Part 3: heat network zones (legislation.gov.uk) | In force |
| Local Heat and Energy Efficiency Strategies | Every Scottish council had to publish a strategy and delivery plan by 31 December 2023, updated at least every 5 years31 December 2023 · Local Heat and Energy Efficiency Strategies and Delivery Plans: guidance (Scottish Government) | In force |
| Scotland's statutory targets | 2.6 TWh of heat from networks by 2027, 6 TWh by 2030 and 7 TWh by 2035Heat Networks (Scotland) Act 2021, section 92 (legislation.gov.uk) | In force |
| Wales | No zoning regime; the Welsh Government is assessing whether the Energy Act 2023 zoning powers are neededHeat Strategy for Wales: action plan (Welsh Government, 2024) | Not yet |
| Ofgem regulation of heat networks begins | 27 January 202627 January 2026 · The Heat Networks (Market Framework) (Great Britain) Regulations 2025, reg. 1 (legislation.gov.uk) | In force |
| Consumer advocate | Citizens Advice, for heat network consumers in England and WalesIf your home is on a heat network (Citizens Advice) | In force |
| Consumer advocate in Scotland | Consumer Scotland, from 1 April 20251 April 2025 · Greater protections for heat network customers in Scotland (Consumer Scotland, Apr 2025) | In force |
| Green Heat Network Fund (GHNF) | Capital grants for new and expanding low-carbon heat networks, with £195m a year confirmed to 2029/30Green Heat Network Fund: guidance on how to apply (GOV.UK) | Announced |
| Heat Network Efficiency Scheme (HNES) | £107m of grants from 2023-24 to 2029-30 to improve existing heat networks in England and WalesHeat Network Efficiency Scheme: overview (GOV.UK) | Announced |
| 2035 ambition | 7% of England's heat (27 TWh) by 20352035 · Warm Homes Plan (GOV.UK, Jan 2026) | Announced |